If you can't compete, litigate. This train of thought has been quite prevalent among major technology companies as of late, most notably by Apple and Microsoft, who both cannot compete with Android on merit, so they have to resort to patent lawsuits and FUD. Both Asustek and Acer have revealed that Microsoft plans to impose royalty fees upon the two Taiwanese hardware makers to prevent them from shipping Android and/or Chrome OS devices.

It wasn't a specific reference to Linux, device companies should migrate away from FAT32 and exFat for their own best interest.

If we are talking devices, we are talking about flash media filesystems aren't we?

Ext4 or Brtfs is best, especially for internal use such as a SSD. No chance of running afoul of Microsft-held patents using either of those. (Write a driver for Windows for interoperability if you must).